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X Corporation has 100 shares outstanding: 60 of which are owned by Ivan and 40 of which are owned by Flo. It also has the

X Corporation has 100 shares outstanding: 60 of which are owned by Ivan and 40 of which are owned by Flo. It also has the following assets that it distributes in complete liquidation:

Gainacre: basis of $100,000 and fair market value of $400,000

Lossacre: basis of ??? and fair market value of $400,000

Cash of $200,000

Ivan and Flo are unrelated individuals.

X corporation received Lossacre four years ago in a Section 351 transaction at a time when the contributing shareholder had a basis in Lossacre of $800,000 and the fair market value of Lossacre was $600,000. No elections were made at the time Lossacre was contributed.

If X corporation distributes each of its assets to Ivan and Flo as tenants-in-common in proportion to their stock interests, meaning Ivan takes a 60% interest in each asset while Flo takes a 40% interest, then:

a.

X corporation will realize a $400,000 loss on Lossacre and recognize $400,000 of it.

b.

X corporation will realize a $200,000 loss on Lossacre and recognize $200,000 of it.

c.

X corporation will realize a $200,000 loss on Lossacre and recognize $0 of it.

d.

X corporation will realize a $400,000 loss on Lossacre and recognize $0 of it

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